⚡ 170 OAK ST

MEMORANDUM

TO: Sunland America Corp. Development Committee

FROM: Senior BESS Site Evaluation Analyst

DATE: October 26, 2023

SUBJECT: Comprehensive Site Diligence Analysis for 170 OAK ST, Brockton, MA (APN: 044 036-095)

This report provides a comprehensive due diligence analysis for the property located at 170 Oak Street in Brockton, Massachusetts, for its potential as a Battery Energy Storage System (BESS) site. The analysis evaluates the site's suitability across key development pillars, including physical characteristics, environmental constraints, grid infrastructure, regulatory landscape, and financial incentives.

1. Site Access & Topography

The subject property is located on Oak Street, a major commercial thoroughfare in Brockton. Based on aerial imagery analysis, road access appears to be excellent. Oak Street is a multi-lane, paved road capable of supporting heavy truck traffic. The property itself appears to be part of a larger commercial shopping center, with existing curb cuts and extensive paved surfaces (parking lots).

• Equipment Delivery: Feasibility for delivering heavy equipment, including multi-ton transformers, switchgear, and containerized battery enclosures, is considered high. The existing road network and on-site paved areas can accommodate oversized loads and staging for cranes.
• Terrain Characteristics: The site is fully developed and appears to be flat and graded, consistent with its current use as a commercial retail parcel. This significantly reduces the need for extensive civil work and site preparation, lowering potential construction costs.
• Heavy Equipment Access: Direct access from Oak Street into the large parking area provides ample maneuvering room for construction vehicles and cranes. No significant topographical barriers are apparent.
• Easement Concerns: While access from the public right-of-way is clear, the parcel is part of a larger development. A title search is required to identify any potential cross-access easements, utility easements, or restrictive covenants associated with the shopping center that could limit the placement of BESS equipment or the gen-tie route. This requires verification.

2. Environmental Constraints

The environmental profile of this site presents both significant risks and a potential, albeit speculative, advantage. The high density of historical industrial and commercial activity in the area warrants a cautious approach.

• FEMA Flood Zone: The FEMA flood zone designation is currently unknown. This is a critical data gap. Any location within a 100-year floodplain (e.g., Zone A, AE) would likely render the site undevelopable for critical infrastructure like BESS or require cost-prohibitive mitigation measures (e.g., elevating all equipment). A FEMA map review is an immediate next step.
• Wetlands: The presence of wetlands is unknown. A desktop review using the National Wetlands Inventory (NWI) is required, followed by a formal wetland delineation if any potential indicators are found. Massachusetts has stringent wetland protection laws (Massachusetts Wetlands Protection Act) with significant buffer zone requirements (typically 100 feet) that could constrain the buildable area.
• Critical Habitat: The data indicates no critical habitat or protected areas on or immediately adjacent to the site, which is a significant positive. This is expected for a highly developed commercial parcel.
• Brownfield/Superfund Status: The presence of 33 brownfield or superfund sites within a two-mile radius is a major red flag. While the subject parcel itself is not listed, this proximity creates a high risk of on-site contamination (e.g., soil or groundwater) from historic uses or migration from adjacent properties. A Phase I Environmental Site Assessment (ESA) is non-negotiable. Conversely, if the site itself can be classified as a brownfield under IRA guidelines, it could unlock a valuable 10% ITC adder. This transforms a key risk into a potential, high-stakes opportunity.
• Pipeline Proximity: No major gas pipelines are identified within a three-mile radius, which is a strong positive from a safety and siting perspective, simplifying permitting and reducing explosion-related risks.

3. Grid Infrastructure & Interconnection

The site's primary strength lies in its proximity to robust grid infrastructure. This provides significant strategic advantages and optionality for project scale.

• Nearest Substation: The "UNKNOWN136273" substation is located only 0.8 miles from the site and has a maximum voltage of 115 kV. This proximity is highly favorable, minimizing the length and cost of a potential gen-tie line. The substation's capacity is unknown and must be investigated through the interconnection process.
• Transmission & Distribution Lines: A 115 kV transmission line is co-located with the substation 0.8 miles away. Additionally, 3-phase distribution feeders are almost certainly present along Oak Street to serve the heavy commercial load. This requires verification via utility maps.